Ralph R. Mazzeo

Ralph R. Mazzeo

Dechert LLP

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New Regulation AB II and NRSRO Rules Released

The U.S. Securities Exchange Commission (the “SEC”) released new Regulation AB II Rules (the “Reg AB Rules”) and regulations relating to credit rating agencies (“the NRSRO Rules”) on August 27, 2014. The Reg AB Rules1 revise...more

9/5/2014 - Asset-Backed Securities Disclosure Requirements New Regulations NRSRO Public Offerings Rating Agencies Regulation AB Reporting Requirements SEC

The Housing Finance Reform and Taxpayer Protection Act of 2014

This article provides a brief summary of the key provisions of a new bi-partisan Senate bill, based on the Housing Finance Reform and Taxpayer Protection Act of 2013, as well as a brief discussion of a new House of...more

4/1/2014 - Housing Finance Reform Housing Market

SEC Re-Opens Comment Period for Asset-Backed Securities Rules

An update to Regulation AB (“Reg AB II”) was originally proposed by the U.S. Securities and Exchange Commission (the “SEC”) on April 7, 2010,1 with an initial comment period open until August 2, 2010 (the “Proposal”) to...more

3/3/2014 - Asset-Backed Securities Public Comment Regulation AB SEC

Impact of Ability-to-Repay and Qualified Mortgage Rules on Residential Mortgage Loan Purchasers, RMBS Participants and Mortgage...

Loan originators, their advisors and service providers are moving rapidly to achieve compliance by January 10, 2014 with the Consumer Financial Protection Bureau’s (“Bureau’s”) new rule, which generally imposes an affirmative...more

10/4/2013 - Ability-to-Repay CFPB Dodd-Frank Investors Mortgages Qualified Mortgage Rule

U.S. Regulators Respond to Public Comments and Restructure Proposed Rule for Credit Risk Retention

One of the important unfinished aspects of the Dodd-Frank Act (“Act”) is the requirement for Federal agencies (“Regulators”) to issue regulations implementing Section 941 of the Act which generally requires that a securitizer...more

9/11/2013 - Asset-Backed Securities Collateralized Loan Obligations Disclosure Requirements Dodd-Frank Investors Mortgage-Backed Securities Qualified Mortgage Rule Risk Retention

Dechert and American Bankers Association Release Strategic Guide to the Ability-to-Repay/Qualified Mortgage Rules; Dechert Follows...

Below is a link to A Strategic Guide to the ATR/QM Rules (Guide), Dechert LLP’s analysis for the American Bankers Association (ABA) of the Ability-to-Repay (ATR) and Qualified Mortgage (QM) rules adopted by the Consumer...more

7/23/2013 - Ability-to-Repay American Bankers Association Guide Lenders Qualified Mortgage Rule

Residential Mortgage Securitization Update: GSE Reform Bill

Senators Bob Corker (R-TN) and Mark Warner (D-VA) have introduced a bi-partisan bill to reform the U.S. housing finance market. Entitled the “Housing Finance Reform and Taxpayer Protection Act of 2013” (the “Reform Bill” or...more

7/12/2013 - Compliance FHFA FMIC Housing Finance Reform Mortgage Insurance Fund Mortgages RMBS

Second Annual IMN CLO and Leveraged Loan Conference Update

The second annual IMN CLO and Leveraged Loan Conference returned to New York this past week. Building on last year’s momentum (discussed here), over 1,500 managers and investors, in addition to structurers, bankers, lawyers...more

4/18/2013 - FDIC Leveraged Loans

U.S. Department of Housing and Urban Development Issues Final Rule Affirming Use of Disparate Impact to Establish Liability for...

The U.S. Department of Housing and Urban Development (“HUD”) issued a final rule (“Rule”) on February 8, 2013, which provides additional support to potential government and private plaintiffs seeking to challenge “facially...more

2/15/2013 - Burden of Proof Burden-Shifting Discriminatory Effects Rule Disparate Impact FHA HUD Legally Sufficient Justification

U.S. Consumer Financial Protection Bureau Seeks Comments to Proposed Amendments to the Ability-to-Repay Requirements and Qualified...

The U.S. Consumer Financial Protection Bureau (the “Bureau”) has released a proposal (the "Proposal") to amend the Bureau's recently issued final rules (the “Rules”) on the definition of a qualified mortgage (“QM”) and the...more

2/15/2013 - Ability-to-Repay Additional Classes of QM CFPB Exemptions Mortgages Qualified Mortgage Rule Rebuttable Presumption Threshold Safe Harbors

Dechert OnPoint Details Recent SEC Report on Credit Ratings for Structured Finance Products

While we’re on the topic of Dodd-Frank rules and regs that could have a significant impact on the securitization market, the SEC recently reported the findings of a study it conducted regarding assigned credit ratings for...more

2/14/2013 - Credit Ratings Dodd-Frank SEC Securitization Market Structured Financial Products

U.S. Consumer Financial Protection Bureau Issues Rules on Qualified Mortgages and Ability to Repay

Congress in the Dodd-Frank Act responded to concerns about the quality of mortgage loans by establishing incentives for lenders to seek to ensure that borrowers had the ability to repay mortgage loans made to them. In...more

1/16/2013 - Ability-to-Repay Borrowers CFPB Damages Dodd-Frank Foreclosure Lenders Loans Mortgages Penalties Qualified Mortgage Rule Rebuttable Presumptions Safe Harbors TILA

Treasury Reports Improvements in Residential Mortgage Servicing

The U.S. Department of Treasury (Treasury) recently issued a report that reviewed the implementation of Treasury guidelines for streamlining distressed homeowners’ communications with mortgage lenders. The Treasury...more

12/4/2012 - Mortgages Servicing Policies Treasury

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